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Mike Boulay -35- April 11, 2011 <br />woody plants; and documentation that DOW has been consulted and that <br />DOW approves of no shrub standard must be provided. <br />CAM: Please see revised page 2.05-36. Revegetation success criteria for the woody <br />plant density for rangeland and fish/wildlife areas will be based upon the <br />greasewood reference area. <br />75. For the diversity success standard, the Division believes it would be <br />appropriate to also include a half-shrub and a perennial grass component. <br />CAM: Please see revised seed mixes SM-1 and SM-2 in Exhibit 4. <br />76. CAM is not proposing to sample for woody stem density in the revegetation. This <br />is based on the as yet to be approved proposal to not include a woody plant <br />density standard. Since shrubs are a major component of the baseline vegetation <br />community, it is likely that shrubs will also be a major component in the <br />reclamation and therefore, the shrub density should be collected. Please include <br />data collection for woody stem density in the reclamation. <br />CAM: Please see revised page 2.05-36. <br />Rule 2.05.4(22)(f) Disposal of Debris Acid Forming and Toxic Forming Materials <br />77. Narrative in this section states that there is no indication that any acid forming or <br />toxic forming materials will be encountered on site. While data in Tab 6 appear to <br />confirm the absence of acid forming materials, the absence of toxic forming <br />materials is not supported, and the narrative will need to be revised. "Toxic <br />Forming Materials" is defined in Rule 1.04 (139) as "...earth materials or wastes <br />which, if acted upon by air, water, weathering, or microbiological processes, are <br />likely to produce chemical or physical conditions in soils or water that are <br />detrimental to biota or uses of water'. Given the fact, as noted in Section 2.04.3, <br />that the surface materials within the land farm evaporation ponds "appear to be <br />sterile since they are completely devoid of vegetation", there is an indication of the <br />presence of toxic forming materials. In addition to the evaporation ponds with <br />exposed industrial waste, there are several locations where buried coke fines <br />would be impacted by site development. Test pit sample data in the Tab 6 "Unit <br />Train Loadout Samples" table indicate elevated levels of numerous parameters, <br />including boron, selenium, iron, manganese, mercury, and zinc, and various other <br />parameters, including high level of total combustible solids in the boiler blowdown <br />material. Please include discussion of the sample results obtained, and <br />interpretation of the results with respect to potential for impacts to plant <br />growth and food chain impacts. Based on consideration of the sample results, <br />address planned measures for handling, and temporary stabilization of the <br />industrial waste materials during site development and operations, as well as <br />final reclamation or disposal of the industrial waste materials that will be